Karabas v. TC Heartland LLC, 2025 WL 777001, No. 24-CV-2722 (AMD) (VMS) (E.D.N.Y. Mar. 11, 2025)
Karabas alleged that Heartland deceptively marketed its
stevia-based sweetener as “100% Natural” when the sweetener’s two ingredients —
stevia leaf extract and erythritol — are synthetic because of the process
through which the defendant produced the ingredients, which were allegedly not
natural. The court granted the motion to dismiss.
There were no allegations that the chemicals used in
production were added to the product:
No reasonable consumer would
conclude that a product contains artificial ingredients merely because it is
produced “in industrial factories” using “synthetic processes.” Indeed, that is
the way most consumer goods are produced. “A reasonable consumer would not
think that a compound found in nature is artificial even if it is produced in a
different way than nature produces it, if the way it is produced is that it is
derived from a natural product and does not contain anything synthetic.”
Moreover, the package included a description of the process
by which the stevia was extracted — that the stevia leaves are steeped in
water, the “sweet parts of the leaf” are extracted, the extract is separated,
filtered, and purified, and the erythritol is fermented. That was sufficient to
clear up any ambiguities, given that the product was a “niche, specialty
product” whose purchasers “are undoubtedly more likely to exhibit a higher
standard of care.”
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